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Q&As refer to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.

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List of Q&A's

CAP for synthetic securitisations of originator institutions in STD based on Article 252

In case of originator institutions using the standardised approach (STD) having synthetic securitisations, is the CAP applied to all the securitised positions or only on the ones where the risk is retained?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3610
  • Topic: Securitisation and Covered Bonds
  • Date of submission:

Weighted average risk weight calculation of the securitised exposures for an unrated securitisation position in STD according to Article 253

How shall the weighted average risk weight of the securitised exposures for an unrated securitisation position in the standardised approach (STD) be calculated? Has the average to be weighted on EAD before the conversion factor (EAD_pre_ccf) or on EAD?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3609
  • Topic: Securitisation and Covered Bonds
  • Date of submission:

Reporting classification of exposures to regional governments and local authorities and public sector entities

For the purposes of populating C 07.00 and C 09.01 CoRep returns, should exposures to a regional government/local authority covered under Article 115(4) CRR or a public sector entity covered under Article 116(4) CRR be categorised for reporting as regional government/local authority and public sector entity exposures respectively (with column 240 reported as appropriate), or should they both be categorised as central government exposures?If reported as exposures to central government in C 07.00 and C 09.01 then for the purposes of populating the LE templates (C 27.00 etc) should the exposure be reported as one to the central government itself or to the specific named regional government/local authority, or public sector entity to which the exposure is incurred?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2017_3603
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Reporting of the interest income and interest expense from hedging derivatives

Our question is in which item of template F 02.00 (FINREP IFRS 9) interest income and interest expense from hedging derivatives classified in the category ”hedge accounting” should be reported, where:the hedging derivatives are used to hedge interest rate risk and are measured at fair value through profit or loss;the dirty price approach is the convention applied by the credit institution; andthe hedged instrument is not measured at fair value through profit or loss (i.e. the hedged instrument is a debt financial instrument whose interest is recognized as “interest income” or “interest expense” in the statement of profit or loss).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2017_3601
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

EBA validation rule v2708_m for DPM 2.6 and 2.7

In the latest version of Annex V of Finrep IFRS9, in the Part 1 paragraph 44 (h) “the immediate counterparties shall be for loan commitments, financial guarantees and other commitments received, the GUARANTOR or the COUNTERPARTY that has provided the commitment to the reporting institution” instead of the debtor of the loan. We would like to know whether this definition refers to all Finrep ITS’ templates or only to some of them. In particular, the use of the guarantor shall apply: • only to template 9.2 “Loan commitments, financial guarantees and other commitments received” or • to template # 9.2 “Loan commitments, financial guarantees and other commitments received”, template # 18 “Information on performing and non-performing exposures” and template # 19 “Information forborne exposures”.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2017_3600
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 25/06/2021

Scope of application of the exemption from the cap on inflows in the Liquidity Coverage Ratio

Is it legally possible for a liquidity sub-group (as per Article 8 CRR) to apply for an increase in the cap on inflows from 75% to 90% (in accordance with Article 33(4) and Article 33(5) of LCR Commission Delegated Regulation (EU) 2015/61) only for the cash inflows generated by one institution in the liquidity sub-group?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement
  • ID: 2017_3598
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 27/04/2018

Template 17 for a financial conglomerate , that elects that none of its entities operating in the insurance sector apply IFRS 9 for financial years beginning before 2021.

How shall a financial conglomerate as defined in Article 2(14) of Directive 2002/87/EC which adopts the deferral of the application of IFRS 9 for its entities operating in the insurance sector (Article 2(8)(b) of the Directive) should fill in template 17 ‘Reconciliation between accounting and CRR scope of consolidation: Balance Sheet’ (in particular, templates F 17.01 and F 17.03), as both financial assets and financial liabilities of the controlled insurance companies will continue to be classified according to IAS 39 and not to IFRS 9?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2017_3596
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 27/07/2018

Low Credit Risk Template 4.4.1 and 4.3.1

Regarding the Column "of which: Instruments with low credit risk" detailed in the Template 4 series. Is there an expectation to have this populated by institutions which have not elected to adopted the practical expediency which IFRS 9 allows for the implementation of the new standard?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2017_3594
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Under Substitution Approach, How to report the covered part of the exposure where collateral is Covered Bond.

How shall the covered part of the exposure be reported where the collateral is a Covered Bond?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2017_3592
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 27/07/2018

IFRS 9, validation rule v2776_m

Validation v2776_m for IFRS 9 (taxonomy 2.7) seems to be incorrect. 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2017_3591
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 11/01/2019

Original Exposure value of Securities Financing Transactions calculated under Article 220 of Regulation (EU) No 575/2013 (CRR)

There appear to be differing interpretations within the industry on how to disclose the Original Exposure value in column 040 of template C 28.00. Some firms are reporting the fully adjusted exposure value as calculated under Article 220 of the CRR (E*). Other firms are including the gross asset value in Column 040 and making an adjustment for the associated collateral in column 300, thereby splitting the SFT transaction into its constituent parts. Can the EBA advise which is the correct treatment?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1423/2013 - ITS on disclosure of own funds requirements
  • ID: 2017_3590
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Retention bonus

Can an institution award retention bonuses to the management board in case of an intended IPO?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/04 - Guidelines on sound remuneration policies under CRD (repealing EBA/GL/2015/22)
  • ID: 2017_3589
  • Topic: Remuneration
  • Date of submission:
  • Published as final Q&A: 25/05/2018

Subsidiary repurchasing AT1 or Tier 2 instruments before five years from the date of issuance

1/ Could an institution’s subsidiary subject to prudential supervision purchase Additional Tier 1 or Tier 2 instruments issued by the institution before five years from the date of issuance of the instruments, given that this purchase would lead to a disqualification of the instruments?2/ Could an institution’s subsidiary not subject to prudential supervision purchase Additional Tier 1 or Tier 2 instruments issued by the institution before five years from the date of issuance of the instruments, given that this purchase would lead to a disqualification of the instruments?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions
  • ID: 2017_3587
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 27/04/2018

Eligibility of Sovereign Guarantee for which Permanent Partial Use Applies against IRB Exposure

When an institution has received permission for permanent partial use of the Standardised Approach for its home sovereign exposures under Article 150 (d) CRR2, does this violate the stipulation under Article 201(2) CRR2 that a guarantor must be internally rated by the institution where the institution uses the IRB Approach?If it is an eligible guarantee, should the guaranteed portion be risk weighted as a Standardised exposure?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3581
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 30/07/2021

Treatment of covered deposits when determining the contribution base of Investment Firms

Can the liabilities that arise by virtue of holding clients' money with investment firms, and that are then deposited by investment firms with a credit institution, be considered as deposits that are deducted from the Contribution Base when determining the ex-ante contribution of those investment firms to a resolution financing arrangement?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/63 - DR on ex ante contributions to resolution financing arrangements
  • ID: 2017_3579
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 18/03/2022

Template F 16.04 line row 070 – relevance for nGAAP

In Annex IV (Financial Reporting for National GAAP based on BAD) of Commission Implementing Regulation (EU) No 680/214 in template F 16.04 excel the row line 070 ”Gains or losses on Financial assets and liabilities held for trading” is not black, while this cell is an IFRS cell. Is it an error?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2017_3578
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Timely payment requirement for unfunded credit protection provided under credit risk insurance policies

Does unfunded credit protection - which a bank has purchased in order to hedge a loan exposure and which provides the protection-seller with the contractual right to compensate credit losses according to the original scheduled payment dates of the hedged loan - fulfil the timely payment requirement for unfunded credit protection in a situation where the loan becomes due and payable prior to the original scheduled payment dates?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3576
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 26/07/2019

Reporting of fees and levies in FINREP template F 02

How each the following expenses should be classified in FINREP template F 02, that is, should they be reported in row 350 (Other operating expenses), row 380 (Other administrative expenses), or under a different item? - contribution to the deposit guarantee scheme pursuant to national legislation implementing Article 10(3) of Directive 2014/49/EU of the European Parliament and of the Council - contribution to the Single Resolution Fund pursuant to Article 70(3) of Regulation (EU) No 806/2014 of the European Parliament and of the Council and Council Implementing Regulation (EU) 2015/81; or to a national resolution fund - a bank levy or a supervisory fee, such as the SSM Supervisory Fee (Regulation (EU) No 1163/2014 of the European Central Bank) or the “Dutch bank tax”.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2017_3574
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

On-site inspections by resolution authorities

Does Article 63(1)(a) enable resolution authorities to carry out on-site inspections to gather relevant information?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3572
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 10/11/2017

Difference between taking control and being able to exercise the control

What is the difference between taking control over the institution and being able to exercise the control?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3571
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 10/11/2017